Category Archives: PUC

HELP US STAND UP FOR COLORADO RATEPAYERS!

​Dear Renewable Energy Advocates–We have an AMAZING opportunity to move clean energy forward in Colorado–but we need your help to “get it right.” ​​Please come to a training below and then to the PUC hearing on Feb 1, 2018. (Docket 16A-0396E “Stipulation” hearing) 

Here are the key dates so far: ​​

Monday January 22, 2018–6 pm,  ​Boulder ​Training

Meadows Public Library,
Boulder​, Colorado​
 (4800 Baseline, behind the Safeway)
Thursday January 25, 2018–6 pm, Denver Training
​Epic Brewing​
3001 Walnut St. Denver, CO 80205 Phone: 720-539-7410 ​
Monday January 29, 2018–​6 pm Lakewood/Jeffco Training
Belmar Library
555 S. Allison Parkway, Lakewood, Colorado
THEN ​HOPING EVERYONE WILL COME….​
Thursday Feb 1, 2018–4​-7​ pm
PUC Public Hearing 16A-0396E

Coal plant retirements, payment plans & replacement options1560 Broadway, #250,Denver 

The February 1, 2018 PUC hearing ​is a critical 
opportunity for the public to help shape the PUC’s response to the need to retire Xcel’s coal plants long before their expected retirement dates. 
This hearing will be about moving the retirement of ​the ​Comanche 1 and 2 ​coal plants in Pueblo ​up about 10 years ​into the ​
2020s. This is, of course, a step in the right direction, but we need your help to make the PUC understand the following:
  • ​Move Faster on Coal Retirements: ​ We are in a crisis on climate change. We can and must move faster by retiring these coal plants ​even ​earlier and working to retire ​the rest of Xcel’s coal fleet much ​sooner also.
  • ​Don’t Rush to Build More Natural Gas: ​Replacing coal plants with wind, solar, storage and demand side options makes good economic and environmental sense. This is not true for building new natural gas capacity which will likely just become stranded in its own time.
  • ​Don’t Make Xcel’s Customers Pay for All of Xcel’s Poorly Considered Expenditures on Coal: Xcel has poured hundreds of millions of dollars into their old coal plants in ​Colorado in this century–including into Comanche 1 and 2. Now Xcel wants us to pay for all of this–and pay them their return​ (think “profit,” at their​ Weighted Average Cost of Capital or WACC) on the ill-considered ​coal plant ​expenditures they have made in recent years. This isn’t a just or equitable solution for ratepayers. If we are to set a ​fair and equitable ​precedent for how we dig ourselves out of the very deep ​hole ​we’ve dug on coal in Colorado, it will be up to the ​informed ​citizens who testify on February 1, 2018 at the PUC to get it done!
 
​Just come to a training and we’ll walk you through 
​the key parts and make sure your statement is on-point and powerful! ​In case you haven’t noticed, climate change impacts are already getting really serious. Please help us move Xcel further, faster on the clean energy path–and when we move Xcel, we move all of Colorado utilities and the entire US utility industry. 
But….We can’t do it without YOU!

Mon. 6/27: A Community Discussion About Our Energy Future with Alice Jackson, Xcel VP for Rates and Regulatory Affairs

Please join Clean Energy Action and Empower Our Future for:

A Community Discussion About Our Energy Future with

Alice Jackson, Xcel VP for Rates and Regulatory Affairs

Monday, June 27th
7 pm
First Presbyterian Church
1820 15th St, Boulder 
(Corner of Canyon and 15th)
This will be an excellent opportunity to hear Xcel’s top PUC witness discuss all that is going on at Xcel and to share with her the concerns of the Boulder community about climate change, decarbonizing our electricity, supporting competition in the solar industry and our vision for a livable future.

Update on Municipalization: The PUC Process

Update on Municipalization: The PUC Process

6 pm to 7:45 pm
Monday, November 16, 2015
Boulder Main Public Library

Boulder Creek Room – Main Floor

Light refreshments will be served at 5:30 pm

Please join Clean Energy Action, Empower Our Future, New Era Colorado, 350 Colorado, and other local groups for an update from:
Deb Kalish, Assistant City Attorney, City of Boulder

Tell the PUC to Uphold Boulder’s Right to Municipalize

Act Now: Tell the PUC to Uphold Boulder’s Right to Municipalize

On November 4, 2015 the Colorado PUC is scheduled to hear Xcel’s Motion to Dismiss Boulder’s application for separation from the Xcel system. We hope you will express your support for the City of Boulder with a short message to the PUC and if you can, by attending the actual proceedings (business attire is best.)

Boulder has a clear Constitutional right to form a municipal utility, but of course Xcel would like to stifle that right in its effort to maintain its monopoly status and to continue to provide electricity that is dominated by coal and natural gas.

If you believe Boulder’s Constitutional right to municipalize should be respected (and/or think we can do better than 30% renewable energy!), then please send a quick note to the Colorado PUC.

Defend Freedom to Access Local Clean Energy

  

The Honorable Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426

Dear Ms. Bose,

We, the undersigned, urge the Commission to find that Tri-State’s proposed lost revenue penalty proposal contained in Tri-State’s revised Board Policy 101 is inconsistent with the Public Utilities Regulatory Policies Act of 1978 (“PURPA”) and the Commission’s implementing regulations.

Rate penalties placed on purchases of power from local qualifying facilities appear to run counter to the spirit and the letter of PURPA. PURPA Section 210 states an intention to “encourage cogeneration and small power production” through rate setting that is “just and reasonable to the electric consumers of the electric utility and in the public interest.”

As we consider the public interest in mitigating climate change and in promoting local economic development, we ask that the Commission deny approval of Tri-State's lost revenue penalty. Tri-State's proposal penalizes utilities like Delta-Montrose for buying local renewable energy that the Commission has said Delta Montrose is obligated to purchase. Approving the rate penalty would essentially undo the Commission's previous decision and hinder, rather than promote, local renewable energy development.

For these reasons, we urge you to reject Tri-State's proposed lost revenue penalty.

Sincerely,

[your signature]

87 signatures

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Additional Actions

Attend the PUC Hearing at 11 am, November 4th at 1560 Broadway, Suite 250 Denver, CO 80202 or watch the webcast.

Read an informative op-ed on the legal background of the proceeding by retired attorney Phil Wardell.

Review Boulder’s municipalization PUC docket.

Decoupling & Demand Side Management in Colorado

Utility revenue decoupling is often seen as an enabling policy supporting “demand side management” (DSM) programs.  DSM is a catch-all term for the things you can do behind the meter that reduce the amount of energy (kWh) a utility needs to produce or the amount of capacity (kW) it needs to have available.  DSM includes investments improving the energy efficiency of buildings and their heating and cooling systems, lighting, and appliances.  It can also include “demand response” (DR) which is a dispatchable decline in energy consumption — like the ability of a utility to ask every Walmart in New England to turn down their lights or air conditioning at the same time on a moment’s notice — in order to avoid needing to build seldom used peaking power plants.

For reasons that will be obvious if you’ve read our previous posts on revenue decoupling, getting utilities to invest in these kinds of measures can be challenging, so long as their revenues are directly tied to the amount of electricity they sell.  Revenue decoupling can fix that problem.  However, reducing customer demand for energy on a larger scale, especially during times of peak demand, can seriously detract from the utility’s ability to deploy capital (on which they earn a return) for the construction of additional generating capacity.  That conflict of interests is harder to address.

But it’s worth working on, because as we’ll see below, DSM is cheap and very low risk — it’s great for rate payers, and it’s great for the economy as a whole.  It can reduce our economic sensitivity to volatile fuel prices, and often shifts investment away from low-value environmentally damaging commodities like natural gas and coal, toward skilled labor and high performance building systems and industrial components.

The rest of this post is based on the testimony that Clean Energy Action prepared for Xcel Energy’s 14AL-0660E rate case proceeding, before revenue decoupling was split off.  Much of it applies specifically to Xcel in Colorado.  However, the overall issues addressed are applicable in many traditional regulated, vertically integrated monopoly utility settings.

Why can’t we scale up DSM?

There are several barriers to Xcel profitably and cost-effectively scaling up their current DSM programs.  Removing these impediments is necessary if DSM is to realize its full potential for reducing GHG emissions from Colorado’s electricity sector.  Revenue decoupling can address some, but not all of them.

  1. There are the lost revenues from energy saved, which impacts the utility’s fixed cost recovery.  If the incentive payment that they earn by meeting DSM targets is too small to compensate for those lost revenues, then the net financial impact of investing in DSM is still negative — i.e. the utility will see investing in DSM as a losing proposition.  Xcel currently gets a “disincentive offset” to make up for lost revenues, but they say that this doesn’t entirely offset their lost revenues.
  2. Even if the performance incentive is big enough to make DSM an attractive investment, the PUC currently caps the incentive at $30M per year (including the $5M “disincentive offset”), meaning that even if there’s a larger pool of cost-effective energy efficiency measures to invest in, the utility has no reason to go above and beyond and save more energy once they’ve maxed out the incentive.
  3. If this cap were removed, the utility would still have a finite approved DSM budget.  With an unlimited performance incentive and a finite DSM budget, the utility would have an incentive to buy as much efficiency as possible, within their approved budget, which would encourage cost-effectiveness, but wouldn’t necessarily mean all the available cost-effective DSM was being acquired.
  4. Given that the utility has an annual obligation under the current DSM legislation to save a particular amount of energy (400 GWh), they have an incentive to “bank” some opportunities, and save them for later, lest they make it more difficult for themselves to satisfy their regulatory mandate in later years by buying all the easy stuff up front.
  5. It is of course the possible that beyond a certain point there simply aren’t any more scalable, cost-effective efficiency investments to be made.
  6. Finally and most seriously, declining electricity demand would pose a threat to the “used and useful” status of existing generation assets and to the utility’s future capital investment program, which is how they make basically all of their money right now.

Revenue decoupling can play an important role in overcoming some, but not all, of these limitations.  With decoupling in place, we’d expect that the utility would be willing and able to earn the entire $30M performance incentive (which they have yet to do in any year) so long as it didn’t make regulatory compliance in future years more challenging by prematurely exhausting some of the easy DSM opportunities.

Continue reading Decoupling & Demand Side Management in Colorado